Loss Limitation Rules; Correction

AGENCY:

Internal Revenue Service (IRS), Treasury.

ACTION:

Correcting amendment.

SUMMARY:

This document corrects final regulations (T.D. 9187, 2005-13 I.R.B.
778) that were published in the Federal Register on
Thursday, March 3, 2005 (70 FR 10319), that disallows certain losses recognized
on sales of subsidiary stock by members of a consolidated group.

DATES:

FOR FURTHER INFORMATION CONTACT:

SUPPLEMENTARY INFORMATION:

Background

The final and temporary regulations (T.D. 9187) that is the subject
of this correction is under sections 337(d) and 1502 of the Internal Revenue
Code.

Need for Correction

As published, T.D. 9187 contains an error that may prove to be misleading
and is in need of clarification.

* * * * *

Correction of Publication

Accordingly, 26 CFR Part 1 is corrected by making the following correcting
amendment:

PART 1 - INCOME TAXES

Paragraph 1. The authority citation
for part 1 continues to read in part as follows:

Authority: 26 USC 7805 * * *

§1.1502-20 [Corrected]

Section 1.1502-20(i)(3)(viii), second sentence, the language “Any
reapportionment of a section 382 limitation made pursuant to the previous
sentence shall have the effects described in paragraphs (i)(3)(iii)(D)(ii)
and (iii) of this section.” is removed and the
language “Any reapportionment of a section 382 limitation made pursuant
to the previous sentence shall have the effects described in paragraph (i)(3)(iii)(D)(2)
and (3) of this section.” is added in its place.